CalARP/RMP/PSM. Program Upkeep Requirements & Common Program Deficiencies. Ken Hufford. 949/ Risk Management Professionals

Transcription

1 CalARP/RMP/PSM Program Upkeep Requirements & Common Program Deficiencies Ken Hufford 949/ RMP

2 Key Topics CalARP/RMP/PSM Key Program Requirements CalARP/RMP/PSM Key Program Upkeep Requirements Common Program Deficiencies RMP

3 Key Program Requirements RMP

4 Regulatory Initiatives Industry Initiatives were absorbed into Performance/ Management System - Based Federal Regulatory Requirements (United States) CFR Process Safety Management of Highly Hazardous Chemicals (February 24) CFR Part 68 - Risk Management Programs for Chemical Accidental Release Prevention RMP

5 Regulatory Initiatives California California - General Industry Safety Orders, Title 8, Chapter 4, Sect Process Safety Management of Acutely Hazardous Materials (February) California - CCR, Title 19, Chapter 4.5, Sect California Accidental Release Prevention (CalARP) Program (November) RMP

6 Who is Required to Submit? Any facility having a hazardous substance over the state threshold is required by the State of California to develop a California Accidental Release Prevention (CalARP) Program. Those facilities meeting the Environmental Protection Agency s (EPA) Risk Management Plan (RMP) threshold quantities also must submit to the EPA. RMP

7 CalARP/RMP/PSM Elements Submittal Management Program Hazard Assessment Prevention Program Emergency Response Program RMP

8 CalARP/EPA RMP/OSHA PSM/Cal-OSHA PSM Program Overlap Compliance Matrix Section EPA (40 CFR) OSHA (29 CFR) Cal OSHA (8 CCR) CalARP (19 CCR) Trade Secrets Process Safety Information (p) (d) 5189 (d) Process Hazard Analysis (e) 5189 (e) Operating Procedures (f) 5189 (f) Training (g) 5189 (g) Mechanical Integrity (j) 5189 (j) Management of Change (l) 5189 (l) Pre-Startup Safety Review (i) 5189 (i) Compliance Audits (o) [IIPP] Incident Investigation (m) 5189 (m) Employee Participation (c) 5189 (p) Hot Work Permit (k) 5189 (k) Contractors (h) 5189 (h) Emergency Response Plan (n) 5189 (n) Article 7 RMP

9 How Did We Get Here? July 2005 CCPS Process Safety Beacon RMP August Risk 2004 Management CCPS Process Professionals Safety Beacon From Houston Chronicle

10 Purpose Document that personnel are safely operating and maintaining a process that utilizes a highly hazardous material Ensure management are dedicating minimum resources needed to prevent accidental releases Training Equipment and Maintenance Personnel RMP

11 Key Program Upkeep Requirements RMP

12 CalARP/RMP/PSM Key Periodic Requirements Annual Review/Update Operating Procedures Emergency Action Plan or Emergency Response Plan Every 3-Years3 Refresher Training Compliance Audit (CalARP/RMP) Every 5-Years CalARP/RMP Submittal Hazard Assessment Process Hazard Analysis (P3) or Hazard Review (P2) External Events (CA only) Non-Incidental Changes in Design or Operation!! Review of several elements, depending on change. RMP

13 CalARP Program 3 Section CalARP Submittal Hazard Assessment Process Safety Information Process Hazards Analysis "CalARP Coordinator Program Maintenance" Initial CalARP Coordinator Responsibility Program 3 Not-In-Kind Change to Process Every Three Years Every Five Years Annual Review/Update Operating Procedures Training Mechanical Integrity Management of Change Pre-Startup Safety Review Compliance Audit Incident Investigation Hot Work Permit Contractors Emergency Action Plan P & IDs RMP

14 Common Program Deficiencies RMP

15 When Do I Resubmit? By the Five Year Anniversary date. OR Change in inventory that altered the Offsite Consequence Analysis distance by a factor of two (i.e. 1 mile to 2 miles). Ownership changes or emergency contact/calarp Coordinator changes. A reportable incident has occurred. RMP

16 Hazard Assessment (HA) Elements Offsite Consequence Analysis Worst Case Scenario Alternative Release Scenario It is recommended that the Hazard Assessment Report consist of an EPA approved Dispersion Model and are structured in a format that is easily updatable and understandable by facility personnel and regulators. RMP

17 Common Deficiencies CalARP submittal CalARP submittal (or RMP Submit) not completed and submitted to agency when necessary Management System is not in place Hazard Assessment Description of scenario selection is not available Revalidation: Failure to update populations, sensitive receptors and maps. RMP

18 Process Safety Information Information pertaining to the hazards of the regulated substances in the process: Toxicity Information; Permissible exposure limits; Physical data; Reactivity data; Corrosivity data; Thermal and chemical stability data; and, Hazardous effects of inadvertent mixing of different materials that could foreseeable occur. Information concerning the technology of the process: A block flow diagram or simplified process flow diagram; Process chemistry; Maximum intended inventory; Safe upper and lower limits for such items as temperatures, pressures, flows or compositions; and, An evaluation of the consequences of deviations. Information pertaining to process equipment : Materials of construction; Piping and instrument diagrams (P&IDs); Electrical classification; Relief system design and design basis; Ventilation system design; Design codes and standards employed; Material and energy balances Safety systems (interlocks, detection, or suppression). Safety Information Hazardous characteristics of the regulated substance (the Material Safety Data Sheets [MSDS] will be used for this purpose) Maximum intended inventory of the process Safe upper and lower limits for key process parameters (temperature, pressure, level, etc.) for the main components of the process Equipment specifications in terms of materials of construction, dimensions, safe operating limits, intended usage, etc. Design codes employed including design conditions and operating limits Safety systems RMP

19 Process Flow Diagram RMP

20 Piping & Instrumentation Diagram (P&ID) RMP

21 Material Safety Data Sheets RMP

22 Process Safety Information Responsibilities: 1. Ensure that the Process Safety Information is readily available to the employees. 2. Update Process Safety Information if a change occurs that makes any key safety-related information inaccurate. RMP

23 Common Deficiencies Piping and Instrumentation Diagrams (P&IDs) are missing or do not reflect changes that have been made to the system Relief system design or design basis not documented Compliance with recognized and generally-accepted good engineering practices not documented Electrical area classifications and electrical distribution system not documented Chemical reactivity hazard evaluations not documented RMP

24 Quiz Process Safety Information is required to be up-to-date (including P&IDs) prior to conducting the Process Hazard Analysis MSDSs can be used to meet all Process Safety Information requirements RMP

25 Process Hazard Analysis/ Hazard Review Identifies hazards of the process chemical, operation and external events that could affect the facility Identifies risk to property, health and life Lists the worst-case consequences Identifies the safeguards in place Provides an objective method to measure the effectiveness of safeguards and need for additional safety features RMP

26 PHA Tool Spectrum Each of these tools provides a different perspective & different insights. Allows Risk Quantification LOPA What-If/ Checklist API RP 14C Review ETA Checklist What-If FMECA HAZOP FTA Less Effort Increased Effort, with Increased Insights RMP

27 Common Deficiencies Process Hazard Analysis (PHA) Five-year updates not done on-time Recommendations not closed or closure not documented Human factors or facility siting not addressed in report Facility siting not based on current design codes & standards Industry-accepted approach not used, or not used correctly Inconsistent consideration of scenarios and risk-ranking External events, including seismic, not addressed RMP

28 Quiz The What-If and HAZOP Study techniques are the most commonly applied for PHAs Required expertise for the PHA Team includes engineering, operations, and PHA methodology RMP

29 Quiz Closure of PHA Recommendations is the responsibility of the facility, and the auditing agency (e.g., EPA, OSHA) would typically not be inquisitive as to status PHA Revalidations are required at least every five years RMP

30 Operating Procedures Procedures: Initial startup Normal operations Temporary operations Emergency shutdown including the conditions under which emergency shutdown is required, and the assignment of shutdown responsibility to qualified operators, to ensure that emergency shutdown is executed in a safe and timely manner Emergency operations Normal shutdown Startup following a turnaround, or after an emergency shutdown RMP

31 Operating Procedures Operating limits: Consequences of deviation Steps required to correct or avoid deviations Safety and health considerations: Properties of, and hazards presented by, the chemicals used in the process Precautions necessary to prevent exposure, including engineering controls, administrative controls, and personal protective equipment Control measures to be taken if physical contact or airborne exposure occurs The operating procedures also include Lockout/Tagout procedures, confined space entry; opening process equipment or piping, and control over entrance into a stationary source by maintenance, contractor, or other support personnel. These safe work practices apply to employees and contractor employees. RMP

32 Common Deficiencies Operating Procedures (OP) Procedure outdated or annual review not performed Written procedures not synchronized with Operator actions Each phase of operation not listed Emergency shutdown procedure job assignments not clear Temporary operations not included Acceptable alarm setpoint range not documented Procedures not in the language of the user RMP

33 Quiz If there have been no changes to the system there is no need to certify the Operating Procedures each year Contractors are not required to follow the facility Operating Procedures RMP

34 Training The training program must address operating procedures, safety, health, maintenance, emergency response, etc. The initial documented operator training must include: Safety & health hazards Emergency operations including shutdown Safe work practices applicable to the operator s assigned job task Safety systems & their functions Operating limits, the consequences of deviating from the operating limits or procedures The training records must include: The identity of the operator trained The date of the training The means used to verify that the training was received & understood by the employee RMP

35 Common Deficiencies Training (TRN) Documentation that demonstrates that training has been performed not available Training does not cover maintenance procedures Training records do not indicate the means used to verify that the employee understood the training Training not in the language of the user RMP

36 Quiz Refresher training on the applicable facility Operating Procedures is required to be completed every three years Training records should document the means used to verify training comprehension RMP

37 Mechanical Integrity/ Maintenance Describes the process and safety equipment preventive maintenance and inspection schedules Can not have a Fix-at-Failure Maintenance Strategy Must have a Preventive Maintenance program based on manufacturer recommendations If a contractor is used, you still must develop a written schedule of what he is replacing, overhauling, cleaning, etc. and on what frequency RMP

38 Mechanical Integrity Regulations require you to: 1. Ensure that there is an established and implemented written procedure to maintain on-going integrity of process equipment, including a procedure to periodically review, document, and approve delays. 2. Ensure that each employee or contractor involved in maintaining the on-going integrity of process equipment is given an overview of that process and its hazards. Ensure that the employee can perform the job task in a safe manner. 3. Perform regular inspection and tests of equipment and perform the required maintenance work. Maintain RMP inspection, testing, and maintenance records.

39 MI Implementation Spectrum Computerized Maintenance Management System (CMMS) Memory of Maint. Mgr. Multi-Industry Application Process Industry Focus Memory of Retiree Complex Functions Key Functions Post-It Notes Use of Maintenance Contractor Self-Standing Web-Based Written on Calendar Simple Scheduling Software Significant Training Requirements Intuitive Potential Effectiveness Challenges Increased Ability to Achieve Objectives RMP

40 MI Program Elements Feedback Requirements Documentation Program Management Insp./Test. Maint./Repair Procedures Training RMP

41 Common Deficiencies Mechanical Integrity (MI) / Maintenance Written procedures related to the ongoing integrity of the process not available, not complete, or not implemented Inspections/maintenance are not occurring or inspection/maintenance frequency is not consistent with industry standards Equipment deficiencies not corrected in a safe or timely manner Facility relies on a Contractor and does not have a written preventive maintenance schedule that it is committed to MI activity NOT DOCUMENTED!!! RMP

42 Quiz A relief valve is one type of equipment typically encompassed by MI Programs The MI Program requires a written procedure, but documenting implementation is left as an option to the facility RMP

43 Management of Change Ensure a safe and systematic method is used to make changes to processes that contain highly hazardous materials Identify the technical basis for any proposed change. Ensure that the changes have been designed utilizing good engineering practices and regulatory requirements Ensure all required modifications to operating procedures, process safety information, and/or other EPA RMP/OSHA PSM documentation have been made Inform and train involved employees of process change and new requirements RMP

44 DETERMINE TYPE OF CHANGE NON CHANGE IN KIND REPLACEMENT IN KIND 1. MOC Form initiated by Originator. Permanent change 2. Identify time necessary to implement change in the MOC Form. 3. Remaining sections of MOC Form completed by MOC Coordinator in conjunction with Departments. 4. Validate Technical Basis and applicable Required Specifications with respect to construction plans. 5. Ensure each department, - Engineering - Environmental Health & Safety - Operations and Maintenance, has completed necessary updates identified in the MOC form. 6. Verify Safe Work Practices as well as Emergency Response updates in consideration of proposed change. 7. Inform and train affected employees and contractors of proposed change and how it will affect operations prior to construction. 8. Construct modification according to specifications. Temporary change 2a. Identify duration of the change in the MOC Form. 2b. Ensure temporary schedule is identified and list of changes is developed using the checklist in the MOC Form. 9. Conduct a PHA and Human Factor checklist. 10. Address PHA Recommendations and Resolutions prior to PSSR. 11. Conduct a PSSR and complete checklist. 12. Address all PSSR Recommendations 13. Submit for Authorization 14. Was all documentation updated and training conducted? YES 15. Was Construction done in accordance to Specifications? YES 16. Confirm PHA was done. Have all recommendations been addressed? YES 17. Confirm PSSR was done. Have all recommendations been addressed? YES Authorize Change NO Back to 5 NO Back to 8 NO Back to 9 NO Back to 11 Startup Modified System Use routing maintenance work order and procedure. No further Action Needed RMP

45 Common Deficiencies Management of Change (MOC) MOC Procedure not current or used Prevention Program documentation not updated to reflect a change in the system RMP

46 Pre-Startup Safety Review Conducted for all new process construction and modified processes to ensure that the system is safe for initial and continued operation Confirms that elements of the Management of Change have been completed Ensures that PHA recommendations have been closed prior to startup. RMP

47 Quiz A Pre-Startup Safety Review must be completed for all process modifications, including in-kind changes RMP

48 Common Deficiencies Pre-Startup Safety Review (PSSR) Written procedures do not exist Pre-Startup Safety Review documentation is not completed or kept on file following implementation of the MOC procedure Documentation is not completed, and signed-off, until after start-up RMP

49 Compliance Audits CalARP/RMP have nearly identical requirements: Certify evaluation of compliance (3 years) Document findings Address deficiencies Retain two most recent audit reports Can be addressed by developing checklists to address: Technical compliance Actual effectiveness RMP

50 Compliance Audit Checklist RMP

51 Common Deficiencies Compliance Audits (CA) Lack of follow-through on recommendations Compliance audit not completed every three years Performing an audit of program, but not supporting with documentation RMP

52 Quiz All past Compliance Audits must be kept on file for the lifetime of the process The 5-Year update satisfies the Compliance Audit requirements An audit by an external agency (e.g., EPA, OSHA) counts as a Compliance Audit RMP

53 Incident Investigation Describes the process of Incident Investigation All incidents must be investigated and reported including near-miss incidents Initiate the incident investigation as promptly as possible (No later than 48 hours following the incident) The report should be reviewed with all affected personnel including contract employees RMP

54 Examples of Near Misses That liquid isn t supposed to be in that tank. Oops, forgot that valve hidden beneath the deck plate. Relief valves relieving is not meant to be normal practice. A relief valve is not a regulator and this is a deviation from the design intent. ESDs or BOPs actuated are not normal shutdown practices. Increased corrosion rates Why? Its great that inspection picked it up but what do we do about it. What s causing it? Is the metallurgy adequate? Fouling of equipment or repeated premature failure of controls and devices RMP

55 Incident Investigation The Incident Investigation report needs to include the following: Date of incident Date investigation began A description of the incident The factors that contributed to the incident (especially root causes) Any recommendations resulting from the investigation RMP

56 Common Deficiencies Incident Investigation not done correctly Incident Investigation team not formed within the first 48 hours of the incident Lack of follow-through on recommendations Findings not shared with affected employees RMP

57 Quiz Incident Investigation procedures only need to be implemented when the system damage is greater than $50,000 The Incident Investigation must be initiated within 48 hours of the incident RMP

58 Common Deficiencies Incident Investigation (II) Lack of follow-through on recommendations Findings not shared with affected employees Incident investigation team is not formed within the first 48 hours of the incident No investigation or documentation of near-misses RMP

59 Employee Participation As part of the RMP/ PSM Program, it is required that employees are consulted on the conduct and development of program elements Employees should have access to elements of the program RMP

60 Common Deficiencies A written Employee Participation plan is not documented and shared with employees. Employees involved in the covered process do not know where RMP/PSM documentation is located. RMP

61 Quiz Employers are required to consult with employees and their representatives on the conduct and development of process hazard analyses RMP

62 Hot Work Permit A procedure must be in place for issuing a hot work permit for each hot work operation conducted on or near the covered process The hot work permit must: Document that the fire prevention & protection requirements as specified in 29 CFR [a] have been implemented prior to commencing the hot work operations Indicate the date(s) authorized for hot work Indicate the object on which hot work is to be performed Be kept on file until completion of the hot work operations RMP

63 Common Deficiencies Employees are not trained nor knowledgeable of the procedures Hot work records are not documented and kept on file Safe work practices (e.g., LO/TO, HWP, Confined-Space Entry, Line Breaking) not followed RMP

64 Quiz Hot Work Permits are not required to be completed when contractors are working on the regulated process RMP

65 Contractors It is the responsibility of the facility to ensure that any contractor going to work on or near the regulated process is qualified and fully aware of the potential hazards associated with the system. When selecting a contractor, obtain and evaluate information regarding the contract owner or operator's safety performance and programs. The contractor owner or operator shall ensure that each contract employee is trained in safe work practices. Periodically evaluate the performance of the contract owner or operator, including training records and verifying safe work practices. RMP

66 Common Deficiencies Contractors (CON) Lack of documentation on contractors that the facility is known to frequently use for handling maintenance or construction Lack of Contractor/Visitor safety training RMP

67 Quiz The Contractors element of the Prevention Program requires that I maintain a file containing at least the following records: qualifications and training records for my contractors, my contractors safety performance records, an evaluation of their onsite safe work practices RMP

68 Emergency Planning & Response If the facility is a first responder, an Emergency Response Program is required. The owner or operator of a stationary source whose employees will not respond to accidental releases of regulated substances need not comply with the Emergency Response Program provided they meet the following: For stationary sources with any regulated toxic substance held in a process above thethreshold quantity, the stationary source is included in the community emergency response plan For stationary sources with only regulated flammable substances held in a process above the threshold quantity, the owner or operator has coordinated response actions with the local fire department; and, Appropriate mechanisms are in place to notify emergency responders when there is a need for a response. RMP

69 Common Deficiencies Emergency Planning & Response (EP&R) ERP vs. EAP Not up-to-date Phone numbers outdated Usability Annual review not performed Training Physicals and fit testing Emergency response equipment RMP

70 Most Common Program Deficiencies RMP

71 Select Citation Summary MOC MI - Oper. OP Recom. MI - Insp. & Test PSI OP PSI PHA MI - Insp. & Test Recom. MI - Oper. MOC PHA Steinway, Seitz, Perry, and Siegel, Before OSHA Comes Knocking, Chemical Engineering Progress, March RMP

72 Common Program Deficiencies The most common program-wide deficiency: ADDRESSING RECOMMENDATIONS RMP

73 Recommendation Follow-up Federal OSHA has the following guidance for Process Hazard Analysis findings: An employer can justifiably decline to adopt a recommendation where the employer can document, in writing, and based upon adequate evidence, that one or more of the following conditions is true: 1. The analysis upon which the recommendation is based contains factual errors. 2. The recommendation is not necessary to protect the health and safety of employees and contractors. 3. An alternative measure would provide a sufficient level of protection. 4. The recommendation is infeasible. RMP

74 Recommendation Follow-up Assign an individual responsible for following up on the recommendation. Assign an anticipated date of completion to each and every recommendation. Document the actions taken for addressing the recommendation, label it as CLOSED and state the date of completion. RMP

75 Things to Remember Even if the facility performs all of the actions of their recommendations (i.e., installing sensors, labeling piping, etc.), if the documentation that originally stated the recommendations is not updated; it is a deficiency. RMP

76 Prevention Program Life Cycle These are living documents. Deficiencies will occur, procedures will change. The idea is to update and follow-up in order to demonstrate you are following your safety program. Development of Program Implementation Following Procedures Evaluation Compliance Audits Improvement Correcting Deficiencies RMP

77 Questions? Ken Hufford (949) ext RMP RMP